CREATING & PROMOTING A CULTURE OF ETHICS & INTEGRITY IN - - PDF document
7/13/2018 1 CREATING & PROMOTING A CULTURE OF ETHICS & INTEGRITY IN GOVERNMENT Saratu Ghartey , Chief Program Accountability Officer NYC Department of Social Services Cynthia Mbu-Etonga , Assistant Deputy Commissioner, NYC Department
Saratu Ghartey, Chief Program Accountability Officer NYC Department of Social Services Cynthia Mbu-Etonga, Assistant Deputy Commissioner, NYC Department of Social Services
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Some psychological reasons:
Downplaying or rationalizing the bad act
The human ability to look at acts and situations in a self-serving way and to rationalize enables most of us to pat ourselves on the backs for being ethical people, yet frequently depart from our own standards
Pressure to perform or conform Pygmalion effect—people act the way they are treated
https://www.inc.com/travis-bradberry/14-psychological-forces-that- make-good-people-do-bad-things.html
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Scott Pruitt, Head of EPA William F. Boyland Jr., NYS Assemblyman Daniel Halloran III, NYC Councilman Efrain González Jr., NYS Senator &
Brian M. McLaughlin, NYS Assemblyman &
Jane Swift, Massachusetts Lt. Gov.
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ETHICS: moral principles that govern a
INTEGRITY: The quality of being honest
Via Oxford Dictionary
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MORALITY and ETHICS often EXCEED THE
What is Right and What is Wrong (Moral/Ethical) Instead of What is Allowed (Legal)
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for maintaining the integrity of government programs and operations. Does not handle complaints of misconduct, nor does OGE have investigative or prosecutorial authority. OGE's mission is one of prevention.
Integrity Reform Act of 2011, which comprehensively reformed the oversight and regulation of ethics and lobbying in New York
by ensuring compliance with the State’s ethics and lobbying laws and regulations. New York State law (General Municipal Law § 806(1)(a)) requires that the governing body for each county, city, town and village adopt an ethics code setting forth the standard of conduct that is expected of its municipal officers and employees.
FEDERAL & STATE (not exhaustive)
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High-profile cases of corruption and
Improving the ethical behavior of
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Walter Shaub, The former head of the OGE (Office of
“To have someone … adopt an attitude of ‘We’re going to do the bare minimum of what is legal, and we’re going to do things that are questionable, as long as there is an argument that, maybe, it’s legal,’ is completely at odds with the way the program has been run for forty years, because we’ve all understood that there is a practice and a body of things that you do to make these bare-bones rules work”
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Clear policies and procedures Training Monitoring Due diligence
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For example: Data shows trends across
Which centers over issuing. Which centers have duplicate issuances Which Employees reviewing cases they
How providers rank in their inspections
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Set the expectation through regular
Compliance newsletters HR communications
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The goal is to ensure that from the
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Make them interesting e.g. Use recent news
Learn from recent internal investigations Highlight findings from internal or external
Welcome feedback and ideas from
Circulate on a regular schedule Develop a platform for these to exist
Intranet, website, SharePoint
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Hotlines and portals for filing complaints,
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Discipline and Enforcement
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Create a transparent process for handling
Employees need to know outcomes (not
Assure staff that reported violations are
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Hotline Management System Make sure adequately staffed and can
Know the Noise vs the Reality
Look for patterns in the noise
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Internal
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HR/Legal- Code of Conduct
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EEO
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Executive Office External
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DOI
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Regulatory oversight agencies
OTDA SDOH / OMIG OCFS 42
Create Compliance Committees Compliance Visibility Compliance Corners Roadshow Compliance Newsletters Share findings and what learned from HOTLINE. Education and Training Tracking & Reporting on consistent training.
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In 2014 NYC DSS created the Office of Program
This office is separate and independent from
It includes, specifically: Office of Compliance & Contract Monitoring Regulatory Compliance Investigations Collections Audit and Quality Assurance
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The Office of Program Accountability is responsible for supporting the integrity of social services programs administered by the New York City Department of Social Services (DSS), and ensuring that DSS is in compliance with all statutory, regulatory, and contractual standards.
We do this through
Client investigations
Provider investigations
Claim establishment and collections
Audits—internal and external
Quality assurance reviews
Contract monitoring
Medicaid trust monitoring
Regulatory compliance
Promotion of an agency-wide culture of ethics and compliance
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Funds are being appropriately spent Fraud and abuse is minimized Risk of lawsuits are mitigated and/or minimized Overpayments are recovered and recouped
Vendors/providers are held accountable Regulations and laws are being followed Public confidence in programs is maintained
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Castro v. City of New York
Castro was fired in 2012 from his position as
Castro declined to falsify the fire safety and
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Tipaldo v. Lynn
Tipaldo was the Acting Assistant Commissioner
Tipaldo and some of his colleagues questioned
After Tipaldo reported the pair, he was phased
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Bonina v. City of New York
Bonina and Coyne were Administrative Law
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Matter of Casale v. MTA
Casale and his colleague Anemone attempted to
carryout a corruption investigation involving the MTA accepting inflated bills & being “wined and dined” by another company attempting to secure contracts with the LIRR.
Casale and Anemone claim they were repeatedly
inhibited in their quest to investigate the corruption internally, and so they finally went to the Queens DA and then the media to expose it.
The MTA holds that Casale and Anemone were actually
the ones obstructing OIG’s investigation, and that they
in order to protect themselves, when really they were the alleged problem.
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Whistleblowing in the NYPD
Det. Jeffrey McAvoy, Det. James E. Griffin, and
After being forced to transfer, their
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Scott Pruitt, Head of EPA
Although this has not yet been brought to
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HRA2
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HRA, 6/25/2018
Leadership sets the example
Fairness and transparency around lapses
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